Correspondence from Dixons Group Plc to
the Minister of State for the Environment 24 November 2000

I am writing to you as a matter of urgency with
regard to proposals to ban the export of appliances that contain
CFCs.

Dixons Group companies have for many years operated
as responsible retailers by offering a service to their customers
that allows for the collection of redundant appliances upon the
delivery of new replacements. All products collected in this way
are passed through a network of approved contractors who manage
the recycling or refurbishment of the items in accordance with
the law and the particular environmental and safety requirements
of Dixons. Refrigerated appliances are just one group of products
that are handled using this mechanism, a proportion of which are
reconditioned and sold overseas where they are a valuable commodity
that continue to be put to good use for many years.

The new EC Regulation on Substances that Deplete
the Ozone Layer (2037/2000) has been designed to prohibit the
export of products containing CFCs. These may be found in refrigerated
products that are over five years old. Current practice ensures
that thee CFCs are removed from the compressor circuit and disposed
of. However, the technology is not available in the UK to remove
CFCs from foam.

A consequence of the rigid application of this
Regulation will be that our contractors will no longer be able
to offer a route for the re-use of the refrigerated products that
we collect. We will then have to reconsider our service proposition
with regard to accepting such appliances from customers. Indeed,
we understand that one electrical retailer has already taken a
decision to no longer collect such fridges and freezers.

The overall result of this approach will be
that a currently well managed and environmentally responsible
trade will be forced out of existence. This will lead to wholesale
indiscriminate dumping which in turn will inevitably result in
the release into the atmosphere of CFCs when such products are
vandalised or crushed for disposal. It will ultimately be Local
Authorities that are left to deal with this increase in problematic
proposal.

The urgency of this letter is because we understand
you are soon to hold a meeting to ratify the ban. We must ask
that, in the first instance, you consider the consequences of
banning the export of CFC impregnated foam in refrigerated appliances
in the light of the negative environmental consequences that will
arise from it.

We understand that while the proposed ban arises
from an agreed EU regulation, most member states have yet to operate
the ban to the level proposed by your Department. Indeed, we believe
only one other member state has agreed to implement this proposal
in a similar way. If the proposal is not applied consistently
across the European Union then massive diversion will occur. However,
even that option would not be left open to contractors in the
UK.

We would hope that further consultation can
resume so that a practical phasing out plan can be agreed, one
that will ensure the proposal achieves its aim of significantly
reducing CFC emissions.